Shelby County Health Care Corporation, doing business as Regional Medical Center, Plaintiff- Appellant,
Southern Farm Bureau Casualty Insurance Company; Medford Farm Partnership; Aaron Medford; Barbara Ford, as Special Administratrix of the Estate of John Dallas Smiley, Defendants-Appellees.
Submitted: September 20, 2016
from United States District Court for the Eastern District of
Arkansas - Jonesboro
COLLOTON, MELLOY, and SHEPHERD, Circuit Judges.
COLLOTON, Circuit Judge.
County Health Care Corporation, doing business as Regional
Medical Center ("The Med, " for short), seeks
relief for alleged impairment of a hospital lien. The
district court dismissed The Med's claim on the ground
that it was barred by the Rooker-Feldman doctrine
and, alternatively, that it failed under Arkansas law. We
conclude that the claim is not barred by
Rooker-Feldman, and that Tennessee law should apply,
so we vacate the district court's order and remand for
hospital lien in question arose from treatment that John
Smiley received at The Med in Memphis, Tennessee, from
February 18, 2009, when he was involved in an automobile
accident, until March 6, 2009, when he died of his injuries.
The Med promptly filed a hospital lien for Smiley's
medical bills pursuant to the Tennessee Hospital Lien Act in
the Shelby County Circuit Court in Tennessee. Tenn. Code Ann.
§ 29-22-101. The Med mailed a copy of the hospital lien
to the attorneys for Smiley's estate.
Ford was appointed administrator of Smiley's estate by an
Arkansas circuit court. Ford negotiated a settlement with the
tortfeasor's insurer, Southern Farm Bureau Casualty
Insurance Company. As part of the settlement negotiations,
Ford sent to the insurer Smiley's hospital bill and
records from The Med documenting Smiley's pain and
suffering. The insurer, along with its insured Aaron Medford,
and Medford's employer Medford Farm Partnership, settled
with Ford for $700, 000. The administrator of the estate
allocated the entire $700, 000 to recovery for wrongful death
and none to the recovery of compensatory damages for medical
services and other expenses.
September 2010, the settling parties (which did not include
The Med) memorialized the agreement in an Arkansas probate
court judgment that purported to extinguish any outstanding
liens. The Med learned of the probate court judgment by April
2011, but did not seek to intervene in the proceedings. The
probate court closed Smiley's estate on September 16,
sued the settling parties to recover $355, 364.16 in damages
for the impairment of its hospital lien. The district court
granted summary judgment for the defendants on the ground
that The Med failed to enforce its lien by neglecting to file
it in the Arkansas probate court. The Med appealed, and this
court reversed, concluding that the district court
misconstrued The Med's claim as one for lien enforcement
rather than lien impairment. Shelby Cty. Health Care
Corp. v. S. Farm Bureau Cas. Ins. Co., 798 F.3d 686, 689
(8th Cir. 2015). We remanded for the district court to
address, among other questions, whether Arkansas law or
Tennessee law applied to The Med's lien impairment claim.
Id. at 689-90.
remand, the district court again granted summary judgment for
the settling parties. The court first ruled that the
Rooker-Feldman doctrine barred The Med's claims.
See D.C. Court of Appeals v. Feldman, 460 U.S. 462
(1983); Rooker v. Fid. Tr. Co., 263 U.S. 413 (1923).
Alternatively, the court reasoned that Arkansas's
choice-of-law rules called for the application of Arkansas
law, and that The Med's claim failed under Arkansas law.
The court concluded that The Med did not properly perfect its
lien under Arkansas law, and that even if the lien were
perfected, it would be unenforceable because Arkansas law
prevents a hospital lien from attaching to a wrongful death
consider first the district court's ruling that it lacked
jurisdiction. In concluding that The Med's claim
"appears to be barred by the Rooker-Feldman
doctrine, " the district court reasoned that "[t]o
now find that there was a valid, enforceable lien would
effectively reverse the decision made by the Arkansas probate
court." The court explained that the probate court found
that The Med's lien was void and not enforceable in
Arkansas, while The Med now alleges that the defendants
impaired a valid lien.
Rooker-Feldman doctrine is confined to "cases
brought by state-court losers complaining of injuries caused
by state-court judgments rendered before the district court
proceedings commenced and inviting district court review and
rejection of those judgments." Exxon Mobil Corp. v.
Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005). The
doctrine does not apply here, because The Med was not a
"state-court loser." The Med was not a party to the
state-court probate proceedings. Whatever narrow application
the Rooker-Feldman doctrine might have to de
facto appeals by non-parties is not germane here, where
The Med has no relationship to the parties in probate court.
Cf. Lance v. Dennis, 546 U.S. 459, 466 n.2 (2006)